1 Environmental Management Plan for the Operation Of

Home , Gochas, Stampriet

ENVIRONMENTAL MANAGEMENT PLAN FOR THE OPERATION OF THE 22KV STAMPRIET- GOCHAS TRANSMISSION LINE IN HARDAP REGION.

October 2019

Compiled by:

Environmental Section

NamPower

P. O . Box 2864

+264 205 2004

Table of Contents

1 LIST OF TERMS, ACRONYMS AND ABBREVIATIONS ...... 3 2 DETAILS OF PROJECT STAFF ...... 4 3 INTRODUCTION ...... 5 3.1 Purpose of this Environmental Management Plan (EMP) ...... 5 4 POLICY AND LEGISLATIVE FRAMEWORK ...... 6 5 ROLES AND RESPONSIBILITIES ...... 8 6 OPERATIONAL PHASE ACTIVITES, MANAGEMENT AND MITIGATION MEASURES ...... 10 6.1 Description of activities related to the operation of the transmission line ...... 10 6.2 MANAGEMENT AND MITIGATION MEASURES ...... 11 7 REPORTING, MONONITORING AND AUDITING ...... 25 8 NON-COMPLIANCE PROCEDURES DURING OPERATION ...... 25 9 RECORD KEEPING ...... 26 10 CONCLUSION ...... 26

1 LIST OF TERMS, ACRONYMS AND ABBREVIATIONS

EAP Environmental Assessment Practitioner ECC Environmental Clearance Certificate EIA Environmental Impact Assessment EMA Environmental Management Act no 7 of 2007 EMP Environmental Management Plan ISO International Organization for Standardization MET Ministry of Environment and Tourism OEMP Operational Environmental Management plan SHEW Safety, Health, Environment and Wellness

2 DETAILS OF PROJECT STAFF

This Operational Environmental Management Plan was generated by staff members permanently employed by NamPower within the Safety, Health, Environmental and Wellness (SHEW) Section. The following individuals took part in the execution of the Operational Environmental Management Plan:

Project Manager – EMP (Operational)

Nadia Haihambo is a fulltime employee of NamPower for the past 9 years and served as the Project Manager for this assessment. She was responsible for ensuring that the correct procedures are adhered to. Ms Haihambo has no vested interest in the outcome of the process. All communication with regard to the project should be addressed to her and she can be contacted at:

Ms. Nadia Haihambo

Email address : [email protected]

Postal address : PO Box 2864; Windhoek; Namibia

Telephone no : 061 – 205 2004

Environmental Assessment Practitioner (EAP)

Martha Ndapona is a fulltime employee of NamPower for the past 2 and half years in the Environmental sub section. She has eight years of experience in Environmental Management having worked in various sectors such as the mining, exploration and energy. She has drafted a number of operational Environmental Management Plans (EMPs) and have been involved in the revision of a number of scoping reports and Environmental Management Plans generated for projects by external consultants. Ms Ndapona has no vested interest in the outcome of the process. Ms Ndapona can be contacted at:

Email address : [email protected]

Postal address : PO Box 2864; Windhoek; Namibia

Telephone : 061 – 205 2614

3 INTRODUCTION

The 22kV Stampriet – Gochas powerline was constructed in 1986. The line with a total length of 415km was constructed to supply farms/settlements along the route.

The 22kV Stampriet – Gochas falls within the vegetation type known as the Mixed Tree and Shrub Savannah (Southern Kalahari). The vegetation structure is classified as open Acacia woodlands while the average plant production is viewed as medium with the variation in plant production estimated at low to medium (Cunningham, 2019).

Fifteen species of larger trees/shrubs are found along this route with 4 species being protected Acacia erioloba (camel thorn), Albizia anthelmintica (worm cure Albizia), Aloe littoralis (Windhoek aloe) and Boscia albitrunca (shepherd’s tree).The dominant tree/shrub species along this route are: Acacia nebrownii (water thorn), Boscia foetida (smelly shepherd’s tree) and Catophractes alexandri (trumpet thorn) with patches of dense Prosopis spp. (mesquite), especially associated with the Auob River, along which most of this line passes, and the Stampriet town lands and elsewhere along the route (Cunningham, 2019).

3.1 Purpose of this Environmental Management Plan (EMP)

The purpose of this EMP is to provide specific environmental guidance for the operation phase for the 22kV Stampriet – Gochas and is intended to manage and mitigate operational activities so that preventable environmental impacts do not occur. The Operational Environmental Management Plan (OEMP) is further aimed at ensuring continuous improvement of environmental performance and reducing negative impacts.

This EMP has the following objectives:

. To outline mitigation measures to be implemented during the operation phase of the transmission line, in order to minimise the extent of environmental impacts and manage environmental impacts associated with the project. . To ensure that the operation activities associated with the transmission line do not result in undue or reasonably avoidable adverse environmental impacts, and ensure that any potential environmental benefits are enhanced. . To ensure that all relevant legislation is complied with during the operation of the transmission line. . To identify key personnel who will be responsible for the implementation of the measures and outline functions and responsibilities . To propose mechanisms for monitoring compliance, and preventing long term or permanent environmental degradation.

4 POLICY AND LEGISLATIVE FRAMEWORK

Table 1 below outlines the legislative requirements which are applicable to the operation for the 22kV Stampriet – Gochas powerline. All the operational activities of the transmission line should be in line with legislations outlined below.

Table 1: Legislation applicable to the operation for the 22kV Stampriet – Gochas powerline.

Legislation: Section (s) Implications: applicable: Environmental  Section 3  All activities performed should be in line with the Management Act no following principles: 7 of 2007 o Interested and affected parties should have an opportunity to participate in decision making o Listed activities should be subject to an EIA o Polluter should pay for rehabilitation o Pollution should be minimized  Environmental assessments should be carried out for  Section 27 listed activities. The proposed activity can be classified under the following range of activities: o Generation of electricity o Transmission of electricity  Section33  These sections details the process to be followed in onwards order to obtain a clearance certificate.  All existing listed activities must obtain a clearance certificate within one year of the law coming into effect (February 2013). Therefore, all existing activities which can be considered a listed activity should apply for clearance. EMA Regulations  Listed activity:  This activity can be considered as electricity GN 28-30 (GG 4878) 5.1 generation and transmission. (February 2012)  6 – 9; 13; 15;  These sections details the process to be followed in 21 -24 terms of producing an Environmental Assessment and this process should be adhered to during the generation of information for this document. Labour Act no 11 of  Section 3  Children under the age of 16 may not be employed 2007  Section 4  Forced labour may not be used during any  Section 9 construction activities.  Section 39 - 42  Basic conditions of employment as stipulated by the law must be met.  The employer shall ensure the health and safety of all employees and non-employees on site. Employees must fulfil their duties in order to ensure their own health and safety and that of other employees and persons. Employees may leave the work site if reasonable measures to protect their health are not taken.

 Section 39 - 42  The employer shall ensure the health and safety of all employees and non-employees on site. Employees must fulfil their duties in order to ensure their own health and safety and that of other employees and persons. Employees may leave the work site if reasonable measures to protect their health are not taken. Electricity Act no 4  Section 33 • Installations used for the provision of electricity should of 2007 be operated with due compliance with the requirements of laws relating to health, safety and environmental standards. Therefore – any company involved within the Electricity Supply Industry must adhere to the laws covering the previously stated aspects or stand to lose their licenses to operate. Water Act no 54 of  Section 21 and  Conditions in terms of the disposal and management 1956 22 of effluent are to be adhered to.  Section 23  Any person causing pollution to a water source shall be guilty of an offence. Public Health Act no  Section 122  It is an offence to cause any form of a nuisance which 36 of 1919 includes water pollution. Water Resources  Section 56  No discharge of effluent may take place without a Management Act no permit 24 of 2004 o Effluent is defined under this Act as any liquid discharge that occurs as a result of domestic, commercial, industrial or agricultural activities Hazardous  Section 27  To provide for the control of substances which may Substances cause injury or ill-health to or death of human beings, Ordinance 14 of by reason of their toxic, corrosive, irritant, strongly 1974 sensitizing or flammable nature or the generation of pressure thereby in certain circumstances;  to provide for the division of such substances into groups in relation to the degree of danger;  to provide for the prohibition and control of the importation, manufacture, sale, use, operation, application, modification, disposal or dumping of such substances; and  to provide for matters connected therewith. Forest Act no 12 of  Section 22  Vegetation may not be removed within 100 m of a 2001  Section 41 river, stream or water course  A person shall be liable for damage caused by any fire which arises as a result of activities carried out on site without having taken reasonable measures to prevent a fire. Fertilizers, farm  Definitions  Arborocide application is defined as an agricultural feeds, agricultural remedy under this Act remedies and stock  Only registered herbicides may be used.  Section 7

7 remedies Act no 36  May only buy herbicides in a container that complies of 1947  Section 10 with the prescribed requirements and is sealed and labelled.  Only allowed to use herbicides in the prescribed manner.  Land owners must be notified about applications, and the following information must be supplied: o Purpose of administration o Registered name and number of the product  Precautions to be taken before, during and after each administration. Nature  Section 74  Protected plants may not be removed or damaged Conservation without a permit. Ordinance no 4 of 1975 Soil Conservation  Section 4  Institutions may be ordered by the relevant Minister to Act no 76 of 1969 construct soil conservation works when and where  Section 13 necessary.  Fire protection schemes may be implemented to  Section 21 regulate the prohibition of veld burning as well as the prevention, control and extinguishing of veld and forest fires.  It is illegal to damage, destroy / fail to maintain any soil conservation works; fire belts; works constructed in terms of a fire protection scheme. National Heritage  Section: 46,  All heritage resources are to be identified and either Act No 27 of 2004 48, 55 protected or removed/mitigated with a permit from the National Monuments Council, before any development may take place  A chance find procedure should be followed in case of discovery of a heritage resource.

5 ROLES AND RESPONSIBILITIES

It is the responsibility of NamPower to ensure that all the environmental management actions are carried out effectively and timeously. It is important to note that the successful implementation of the EMP is, however dependent on clearly defined roles and responsibilities by several stakeholders. Below are the key employees that are responsible for the management of environmental and social issues during the operation of the power line:

The Area Superintendent shall ensure that:

. This EMP is enforced . Environmental requirements are adequately covered in any external service providers contracts. . SHE requirements are included in the tender documents sent to the contractors. A copy of this EMP should also form part of the tender documents.

. Corrective actions are implemented for non-compliances . Appropriate records and information regarding compliance with environmental requirements are maintained. . The power line remains in compliance with the requirements of this EMP, through regular communication and monitoring.

The NamPower SHEW Section shall:

. Ensure that all requirements with regards to this EMP are fulfilled. . Assist the Area Superintendent in ensuring the station remains in compliance with this EMP. . Provide SHEW inductions for the external service providers and awareness training for the employees . Organize and implement monitoring and audit functions, in consultation with the District Superintendent . Audit the implementation of this EMP. . Advise the district employees on actions or issues impacting the environment and provide appropriate recommendations to address these issues.

In case an external provider has been sourced to conduct work on the power line, the project manager and contractor has the following responsibilities:

Project Manager shall:

. Enforce this EMP . Ensure that SHE requirements are included in the tender documents sent to the contractor. . Ensure that a SHEW clause is included in the contract document and communicated to the contractor before the inception of the project. . Ensure that the contractor remains in compliance with the requirements of this EMP, through regular communication and monitoring.

The Contractor shall:

. Shall adhere to all tender and contractual requirements . Implement this EMP . Ensure all tasks undertaken under the scope of work, are in accordance both with NamPowers’ SHEW policies and procedures as well as to the requirements of this EMP. . Put in writing a system of communication, in which all incidents and accidents are reported to the SHEW section . Ensure that all employees receive a SHEW induction before the start of the project. . Ensure that the work conducted does not contribute to environmental degradation, affect human health and safety as well as create a nuisance to any being working, residing or living on adjacent properties or within the immediate surroundings of the site.

6 OPERATIONAL PHASE ACTIVITES, MANAGEMENT AND MITIGATION MEASURES

6.1 Description of activities related to the operation of the transmission line

The following activities are associated with the operation of this powerline and their associated potential impacts:

Table 2: Description of the activities related to the operation of this transmission line. Activity Description Associated potential impacts General functioning Physical presence and . Bird mortalities through collisions of the transmission functional characteristics of with powerlines. line (live power lines) the line . Visual impact. . Community impacts in a form fatalities or injuries caused by electrocution. . Provision of electricity to communities. Periodic Replacement, cleaning and . Soil and ground water inspections, maintenance of line contamination as a result of oil monitoring, components spills maintenance of the . Soil contamination as a result of line improper waste handling and disposal. . Loss of biodiversity if existing access roads are not put to use. . Veld fires. Installation of Optic Design, Supply, Delivery, . Loss of biodiversity if existing Fibre networks Installation, and access roads are not put to use or Commissioning of Optic Fibre there will be a need to do bush networks clearing. . Soil contamination as a result of improper waste handling and disposal. Vegetation Selective herbicide . Loss of biodiversity due to clearing management within application, mechanical and operation. the servitude manual bush clearing . Soil and groundwater contamination. . Loss of sensitive habitat. . Loss of archaeological resources. . Possible temporary employment opportunities. Environmental Periodic environmental . Littering monitoring (e.g. monitoring and audits to surveys for bird assess compliance to collisions)

management procedures, and EMP requirements.

6.2 MANAGEMENT AND MITIGATION MEASURES

In order to ensure that the potential impacts are eliminated and/or minimised, it is necessary to ensure that the various activities related to the operation of this powerline are adequately managed and monitored. Table 3 below outlines mitigation measures as well as objectives to be achieved. A responsible person (s) have been assigned to each mitigation measure (s).

Table 3: Proposed mitigation measures for the general operational activities

ASPECT MANAGEMENT AND MITIGATION MEASURES/COMMITMENTS Responsible person (s)

Environmental . All employees both internal and external to receive environmental . SHEW Awareness awareness training and refresher environmental awareness training to . Area Superintendent be made available when required. . Project Manager . All contractor employees to receive induction before any work is commenced on the power line. . All employees are to be made aware of their individual roles and responsibilities in achieving compliance with the EMP. Loss of biodiversity . Existing access routes and disturbed areas should be utilised as far as  Area Superintendent possible to access power line route.  Project Manager . Vegetation clearing must be kept to the absolute minimum servitude  Contractor required for safe operation of the power line. . Maintenance vehicles should be restricted to drive only on designated access roads to limit the ecological footprint of the power line. . No faunal species must be harmed by maintenance staff during any routine or/and emergency maintenance on the transmission line. . Avoid use of machinery in the vicinity of watercourses; General and Hazardous . Minimal waste will be produced during the operation of the . Area Manager waste Management transmission line. However, any solid waste produced during . Area Superintendent maintenance operations must be disposed of at an approved and . Contractor permitted waste disposal site. . During maintenance, should any oils spills or leaks occur from maintenance vehicles, the contaminated soil must be removed, remediated or transported to hazardous waste disposal site. . Ensure that no waste material is left behind on site

. Monitor site for observable waste Electric shock hazards . Anti-climbing devices should be installed on transmission towers and . Area Superintendent be maintained. . Appropriate warning signs must be placed on the facilities Heritage resource . Any chance finds must be reported to NamPower environmental . Area Superintendent section. . Project Manager . In the case of an chance find of a site or material of archaeological or . Contractor cultural significance, the following procedure shall be adhered to:  Person identifying archaeological or heritage material If operating machinery or equipment stop work  Identify the site with flag tape . In an event of discovery of human remains or other artefacts the work shall cease. A professional archaeologist is to be consulted and carry out investigation. . Any new sites discovered shall be reported to the National Heritage Council and relevant experts in the field . Known archaeological and cultural sites shall be demarcated and damage to the sites avoided. . Any damage which may occur shall be reported immediately and the relevant experts contacted to provide remediation advice Bird collisions along . Carry out inspections for bird collisions. . Area Superintendent sensitive areas of the line . Compile report on any collisions observed. . District personnel . Submit reports on collisions to SHEW section . Develop and implement additional mitigation measures where required . Monitor success of mitigation measures Veld fires . Ensure that all cars are equipped with fire extinguishers . Area Superintendent . Ensure that all fire extinguishers are regularly inspected and serviced . Project Manager . Ensure that any veld fire is immediately extinguished, reported and . Contractor investigated

Table 4: Proposed mitigation measures activities related to vegetation management

ASPECT MANAGEMENT AND MITIGATION MEASURES/COMMITMENTS Responsible person (s)

Social Impact . Personnel should be properly educated about the impact of HIV/AIDS and other . Project Manager communicable diseases . Contractor . Any person making themselves guilty of violence, harassment or any other activity deemed inappropriate by the landowner, must immediately be removed from site. . Intoxicating liquor or drugs of any kind may not be used or supplied on site by any person or any member of public. . The site Supervisor shall at any site meeting report on the status of the implementation of all provisions of the EMP. . The contractor shall inform NamPower District personnel at least 21 days before starting work on site

Interaction with landowners and other interested and affected parties

. NamPower District Personnel shall take the responsibility of communicating with landowners and neighbours at least 14 days prior to applying herbicides on site. . The following information shall be communicated to landowners and other interested and affected parties:  Time of application  Duration of application  Type of herbicide to be used  Reasons for application  Persons responsible for application . All conditions and requirements stated by the landowners shall be documented and adhered to by NamPower employees and contractors and should be incorporated into the specific conditions for applications of this EMP prior to work starting on site. . Ensure that all queries and complaints are documented and dealt with. . All communication received from landowners shall be responded to within 3 days of the complaint or query being received. . Existing infrastructure may not be tampered with or damaged during vegetation management.

Access to Site

. Established access routes shall be used to gain entry to a site. . Only individuals with the necessary training and induction shall be allowed to operate on site . Landowners and asset owners shall have sufficient warning prior to any work starting on site . Camp sites may only be established on sites if prior permission was received from the landowner . All other parts of the property shall be considered as private property and off limits to any person involved with vegetation management other than the servitude to be cleared; established access routes and camp sites

Temporary Campsites

. Should the contractor wish to camp on site, the exact campsite location, remuneration, approximate dates of occupation and any special conditions with the relevant landowner should be arranged at least two weeks prior to site establishment. . The location of campsites must be discussed with the landowner and the contractor may only use those areas indicated by the landowner. . Care should be taken to protect campsites from large mammals, without causing harm or injury to animal . Throughout the period of the contract, activities are to be restricted to the designated area. . Adequate ablution facilities must be provided to the staff. These facilities may not be located within 100m of any river, stream channel, pan, dam or borehole (even if the water source is dry) and should be properly maintained in a hygienic and good working order. . Toilet facilities should be available in the following ratio: one (1) toilet for every 15 females and one toilet for every 20 males

. The staff should be properly trained on the procedure that should be followed when no ablution facilities are available such as when employees are working in the within the servitude . . Fire extinguishers, first aid kits and any other relevant safety equipment must be easily accessible at all times.

Waste . On site waste management facilities are to be provided by the contractor. . Project Manager Management . Separate waste containers must be provided for hazardous and general waste . Contractor

. Waste containers shall be provided with lid or netting to prevent waste from being removed by scavengers or wind and should not be over-filled. In areas with a high frequency of animals, the area should also be cordoned off

. Illegal dumping and littering shall not be tolerated

. The workforce must be sensitised to dispose of waste in a responsible manner and not to litter.

. No waste may be burned on site

. No waste may remain on site after completion of the project

. A temporary storage site shall be established on site in order to ensure that waste management can be done in a consolidated manner.

. Temporary storage must be managed in such a manner as to ensure that no runoff or leachate from site can occur.

. All waste management requirements as stipulated in the Arborocide application procedure shall be adhered to and inspections and audits shall be carried out accordingly

Water Resources . Herbicides shall not exceed the recommended volume and concentration of application. . Project Manager

. Application shall be done within the period specified in the specialist reports . Contractor

. The type of herbicide to be used shall be specified in the specialist report.

. Herbicides shall not be applied within 50 metres of a water body including boreholes etc.

. Surface and ground water shall not be polluted under any circumstances. Storm water shall be managed to ensure that it does not become polluted.

. Water must be used sparingly.

. Naturally occurring water resources may not be used for any personal hygiene, mixing herbicides or for washing equipment used for herbicide application.

. Water may only be taken from a private or government property based on an agreement between the Contractor and custodian of the water source.

Fauna and Flora . No herbicide shall be used that can bio-accumulate in any animal product to be used . Project Manager either personally or that is destined for local or international markets . Contractor . Herbicides which pose a significant risk to any animal or organism, as indicated by the label of the project, may not be used.

. Poaching or capturing of any animal (wild or domestic) shall be prohibited.

. Bird nests may not be disturbed.

. Only the herbicides specified in the applicable specialist reports shall be used on site given that these herbicides are registered in Namibia

. Herbicide application shall be in accordance with the labelled instructions of the herbicide in question.

. Regular monitoring of the site shall be done in order to identify potential non-target species affected by the application process.

. Daily site reports shall be kept of the application process, as specified in the NamPower herbicide application procedure

Hazardous . All waste generated through any process related to the application of herbicides, . Project Manager Materials including left-over herbicide mix that will not be used later and empty herbicide containers, shall be treated as hazardous waste. . Contractor

. A register shall be kept of all hazardous substances and must be available on site

. Storage areas shall display the required safety signs as stipulated on the labels of the chemicals to be used

. Herbicides shall be stored in their original containers where possible.

. Storage containers for herbicides shall always be labelled according to its content and safety, health and environmental hazards.

. Storage of herbicides shall be done in accordance with the MSDS and / or label of the herbicide in question.

. Herbicides should be stored in a cool, dry area where food and drinks are never stored or prepared.

. The storage area for herbicides and hazardous waste should be lined with plastic or impermeable material to prevent leaks from reaching the soil.

. Liquid waste must be stored in leak-proof containers which should be closed with a lid when not in use.

. No herbicide shall be stored on site for a period exceeding the expiry date of the product.

. Storage sites shall be inspected on an annual basis.

. Access to storage sites shall be regulated and controlled.

. The staff should be properly trained on how to respond to accidental spillages of herbicides.

. Accidental spillages shall be cleaned up immediately. In case of a spillage, the MSDS and / or label should be consulted for spillage clean-up measures.

. A spill kit and/or absorbent materials should be on site for spill containment and clean- up – under no circumstances should straw or any similar material be used to manage herbicide spills

. All hazardous waste shall be disposed of at a hazardous waste disposal facility.

Herbicide Use . Chemicals should not be applied to areas deemed to be highly sensitive especially water . Project Manager features (e.g. rivers, farm dams) classified as “high” sensitivity, but rather revert to hand clearing . Contractor

. Avoid the spraying of protected tree species. Some tree species e.g. Boscia albitrunca are not expected to reach heights potentially interfering with the transmission lines although within the 12m section.

. Eradicate all invasive alien species e.g. Prosopis spp. – associated with the lines (especially the Auob River and the Stampriet town lands). This would indicate overall environmental commitment

. Target only problematic species i.e. bush thickening species and species potentially affecting the power lines within the servitude area.

. Avoid spraying herbicide during windy days/periods. See the general product requirements for herbicide used. This could affect non-target areas and species.

. Avoid spraying, removing and/or approaching trees with vulture (and other larger raptors) nests along the route.

. Herbicide should be applied directly to the plant – stem or leaves – as a spray.

. Manual vegetation removal should be encouraged.

. Herbicide will be handled in accordance with the requirements outlined in the NamPower Herbicide and Pesticide Management procedure.

Manual and . Obtain the permit to remove the protected trees from the Ministry of Agriculture, Water . Project Manager Mechanical and Forestry as per Forest Act No. 12 of 2001 (Licence conditions for bush control). Vegetation . Contractor Removal . Measures must be put in place to avoid erosion at rivers, stream channel crossings, and at places where existing erosion scars and dongas are encountered to avoid any further erosion at these points.

. Where manual bush-clearing is impractical, mechanical bush clearing shall be used, but an effort must be made to preserve the topsoil structure.

. Where clearing is done near a river, the contractor/NamPower must ensure that no felled bushes/branches/shrubs are left behind in the riverbed.

. No burning of bush cleared materials is allowed onsite.

. When blading, the blade should be kept above the soil surface to minimize erosion and impacts to small plants, and root of larger plants

. Cut vegetation to a height close to ground level

. No hand-made tools allowed on site

. Manual and mechanical vegetation removal should be done in accordance with NamPower Servitude Management and Bush Clearing Procedure.

6.2.1 Vegetation management Method

For the Stampriet- Gochas 22kV transmission line, manual clearing e.g. hand axe/panga, etc. or motor-mechanical clearing e.g. chainsaw, etc. is recommended on calcrete soils while on sandy soils (e.g. parts of the route just south of Stampriet) mechanical clearing could be used. The rationale therefore is as follows:

 Sandy soils not susceptible to erosion – mechanical;  Calcrete soils and undulating rocky terrain along the Auob River is more susceptible to erosion and located along the important Auob River – manual;  Potential “problem” Acacia erioloba individuals (and ornamental trees in farmsteads) i.e. tall trees should be targeted;  Pruning of selected branches of tall Acacia erioloba individuals not growing directly under the line is recommended; and  Potential “problem” areas i.e. dense bush occur in patches only e.g. Prosopis spp. (Auob River and Stampriet town lands)

However, regrowth of the various species felled by manual and/or motor-manual is guaranteed and would have to be managed or else clearing would only have short term benefits. Chemical control measures are therefore suggested to prevent/suppress regrowth of coppice. However, no granular herbicides should be used as these are not target/species specific, but mobile resulting in non-target species being affected.

According to the vegetation assessments conducted by the specialist in the area for the 22kV Stampriet – Gochas, when herbicide application is used as a method of vegetation management, the following site specific management requirements were identified:

Table 5: Site specific management requirements for herbicide application

Management requirement Responsible Person (s)

General - Access 240 SL or any similar product with picloram or tricoplyr as . District supervisor / superintendent active ingredients should be used . SHEW section Prosopis spp. - Confront 360SL or any other similar products with the active ingredients: Triclopyr (Pyridine compound – triethylamine salt) or . Contractor Clopyralid (Pyridine compound – triethylamine salt)

. Foliar application – spray – is recommended as this is target specific. . District supervisor / superintendent Access mixed with water and Actipron (wetting agent). . SHEW section

. Contractor

. The herbicide can be applied directly to the plant – stem or leaves – . District supervisor / superintendent as a spray. Trees and shrubs with a stem diameter <10cm can be sprayed directly, but trees with a stem diameter >10cm should be . SHEW section felled before treatment of the cut surface for best results. Treatment . Contractor should be done as soon as possible after felling and the entire cut surface and stump should be wetted. Coppice growth can also effectively be controlled.

. Active growing season – i.e. September to April (best in early growing . District supervisor / superintendent season – September to November – before main rains) has best results. . SHEW section . Contractor

. Foliar application = 350ml/100l water + Actipron Super 500ml/100l . District supervisor / superintendent spray mix. . SHEW section

. Contractor

. Cut stump application = 2l/100l water + Actipron Super 2l/100l spray . District supervisor / superintendent mix. . SHEW section

. Contractor

. Year 1: Apply herbicide (early growing season) . District supervisor / superintendent

. SHEW section

. Contractor

. Year 2: Follow-up to target any regrowth and coppicing (early growing . District supervisor / superintendent season) . SHEW section

. Contractor

. Thereafter: As required – i.e. dependent on coppicing potential of . District supervisor / superintendent various species. This could be determined during routine line inspections. . SHEW section . Contractor

7 REPORTING, MONONITORING AND AUDITING

Environmental monitoring and audits must be conducted during the operational phase of the transmission line. The environmental monitoring and audits conducted along the power line will cover all management procedures, the requirements of this plan and will be carried out by the NamPower SHEW section. Monitoring and audit reports detailing the monitoring and audit results shall be prepared by the SHEW section and communicated to the Area Manager and Superintendent. Records of monitoring and auditing report shall be kept and will be made available during inspection and audits.

The following general monitoring indicators and guidelines are recommended should herbicides be used to do vegetation management along the line:

Table 6: General monitoring indicators and guidelines recommended after herbicide application

Monitor trees adjacent the cleared area A survey in year 1 (i.e. 6 months after application of after herbicide application herbicide) should be conducted along the affected route to determine the effect of the herbicide on non-target areas – i.e. adjacent vegetation. Focus on protected tree species along the route Monitor coppicing and regrowth after A survey in year 2 (i.e. 1 year after application of herbicide application herbicide) should be conducted along the affected route to determine the effect of the herbicide on bush clearing. This would indicate the success of the herbicide used as well as indicate the necessity of follow-up treatment.

8 NON-COMPLIANCE PROCEDURES DURING OPERATION

The Area Superintendent shall ensure that the employees and external service providers comply with the requirements outlined in this EMP. In the event of non-compliance the following recommended process shall be followed:

 Non-compliances will be identified during inspections or audits carried out by the SHEW Section and reported to the Area manager and Superintendent for corrective actions.

 Area Superintendent shall notify the employees about the non-compliance

 Corrective and preventative actions must be implemented on an agreed timeframes

 Follow – up inspections shall be conducted to assess whether the corrective and preventative actions were implemented effectively

9 RECORD KEEPING

Record keeping is important for the effective functioning and implementation of an EMP. EMP documentation must be kept in both the hard copy and electronic format for safe keeping. These must include:

. Copy of the Environmental Clearance Certificate

. A copy of an EMP

. EMP implementation activities

. Induction records

. Audit and Inspection reports

In case vegetation management is conducted and is done using herbicides, the following records should be kept:

. Date of application . Herbicide applied . Persons responsible for application . Supervisor . Type of herbicide used . Method of application . Timing of application . Equipment used . Concentration of herbicide used

10 CONCLUSION

All management measures and legal requirements outlined in this EMP should be complied to in order to ensure environmental compliance by all parties undertaking the operational activities. This will ensure that potential negative impacts are identified, avoided or mitigated.